One of the policies adopted within PGE CG to manage material sustainability-related issues in the area of political engagement is the Regulatory Management Procedure.
Under this procedure Regulatory Management in PGE CG has been implemented, understood as a set of activities aimed at shaping Regulations in a manner favourable to PGE CG, particularly intended to:
- identify regulatory opportunities and threats,
- shape regulations to positively impact the financial performance of PGE CG,
- mitigate risk, including operational risk as well as risks related to investment and maintenance activities associated with changes in the regulatory environment,
- create new business areas,
- build consensus with key stakeholders influencing the regulatory environment,
- develop and update uniform Regulatory Management principles across PGE CG.
According to the procedure, regulations refer to all newly created (drafted) legal provisions and administrative acts, legislative initiatives, revisions of existing legal norms, as well as non-legislative documents leading to the legal shaping of the energy sector at the national and European level, as well as any internal (PGE CG) regulatory initiatives that may help shape the regulatory environment in line with the interests of PGE CG.
The Regulatory Management Procedure covers draft regulations concerning the energy sector, industry-specific regulations shaping the energy sector, and activities related to future Regulations across all PGE CG companies, taking into account the Compliance Programme applicable at PGE Dystrybucja S.A. The procedure does not include management of compliance with existing regulations or management of general economic regulations not directly related to energy sector regulations.
One of the key principles of the Regulatory Management Procedure is ensuring the consistency of regulatory positions presented by PGE CG. The Regulatory Department and the International Relations Department are responsible for coordinating PGE CG’s communication with external stakeholders regarding national and international regulations. Any positions related to regulations that are to be communicated by organisational units of PGE CG to external stakeholders must first be agreed upon and approved by the Regulatory Department (for national regulations) or the International Relations Department (for international regulations).
The key activity in the area of regulatory management is the presentation of PGE CG’s position, understood as the Group’s main expectations and demands regarding a given regulation, to external stakeholders. External stakeholders, as defined in the Regulatory Management Procedure, are institutions, entities or bodies at the national or European Union level that influence the formation of regulations, such as government administration bodies (relevant ministers), the Sejm, the Senate, the President of the Energy Regulatory Office, the President of the Office of Competition and Consumer Protection, and EU bodies – the European Parliament, the Council of the European Union, and the European Commission.
The highest level within PGE CG responsible for implementing the Regulatory Management Procedure is the Management Board of PGE S.A. The member of the management body responsible for overseeing the company’s political influence and lobbying activities is the Vice-President for Regulatory Affairs at PGE S.A.
PGE CG does not engage in activities or have any commitments related to exerting political influence, understood as making political contributions.
PGE CG does not make financial contributions either directly or indirectly, and no such cases occurred in 2024.
PGE CG also does not make in-kind contributions either directly or indirectly. As PGE CG does not provide in-kind contributions, it does not estimate their monetary value.
PGE CG undertakes activities aimed at shaping regulations favourably by presenting its positions on draft legislation in ongoing public consultations to external stakeholders and by independently proposing amendments to legislation that positively affect its business operations, for example by notifying the relevant ministries of the need for legal changes in a specific area. PGE CG carries out these activities both at national and international level, independently and through participation in industry organisations that act in the interest of their members (including by proposing changes to legislation that are beneficial to the industry and their members, also with a view to reducing the cost burden on end consumers of electricity and heat).
PGE CG companies are members of over 50 industry organisations (most of which are local chambers of commerce). The key national and international industry organisations for PGE CG include: the Polish Electricity Association (PKEE), Eurelectric (via PKEE), the Polish Society of District Heating (PTEC), the Polish Power Transmission and Distribution Association (PTPiREE), the Polish Power Plants Economic Society (TGPE), the Energy Trading Association (TOE), the Polish Wind Energy Association (PSEW), Energy Traders Europe (ETE), Eurogas, Euroheat&Power, Cogen Europe, European Distribution System Operators (E.DSO), EU DSO, United Nations Global Compact (UNGC), Wind Europe (WE), and the International Union of Railways (UIC).
PGE CG companies’ membership in industry organisations was not a legal requirement.
The main topics addressed by lobbying activities in 2024 and the company’s main positions in this regard included:
REGULATION (EU) 2021/1119 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 30 June 2021 establishing the framework for achieving climate neutrality and amending Regulations (EC) No 401/2009 and (EU) 2018/1999 (‘European Climate Law’). Position: A reduction target of 75–80%; better balancing of reduction burdens across sectors; excluding greenhouse gases other than CO₂ from the ETS; maintaining free allocation of allowances for district heating; assessing the impact of the reduction target at the individual Member State level; and a separate decarbonisation plan for district heating.
Commission Implementing Regulation (EU) 2019/1842 of 31 October 2019 laying down rules for the application of Directive 2003/87/EC of the European Parliament and of the Council as regards further arrangements for the adjustments to free allocation of emission allowances due to activity level changes. Position: Ensuring the possibility of annual allocation of an additional pool of free CO₂ emission allowances for district heating during the implementation of investments aimed at achieving significant emission reductions, i.e. starting from 2026, which will support the decarbonisation of district heating by reducing expenditure on emission allowances.
Directive of the European Parliament and of the Council on corporate sustainability due diligence and amending Directive (EU) 2019/1937 (Corporate Sustainability Due Diligence Directive, CSDDD). Position: Limiting the material scope of the Directive to the company’s supply chain; allowing parent companies to fulfil the obligations arising from the Directive on behalf of their subsidiaries; the transition plan required by the Directive should be the same plan as required under Directive (EU) 2022/2464 of the European Parliament and of the Council amending Regulation (EU) No 537/2014, Directive 2004/109/EC, Directive 2006/43/EC and Directive 2013/34/EU, as regards corporate sustainability reporting (Corporate Sustainability Reporting Directive, CSRD); removing the obligations imposed on directors by the Directive; removing the prohibition of public support for companies penalised under the provisions of the Directive.
Network Code on Demand Response (NC DR). Position: Taking into account issues related to distribution system operators and their role under the changed conditions of the energy market (including the rapid development of RES, bidirectional energy flows); indicating the local nature of the solutions applied in demand-side response (definition of local services, local market and provider of local services); the local market operator should be the DSO, and only exceptionally the TSO.
Advocating for amendments to the Act of 27 October 2022 on extraordinary measures aimed at limiting electricity prices and supporting certain customers in the years 2023–2025 regarding the contribution to the Price Difference Payment Fund. Position: Clarification that the contribution to the Fund should be calculated based on the applicable statutory (maximum) prices and for the entire period of the obligation jointly (13 months); granting compensation for the reduction provided to customers in 2023 in the amount of PLN 125.
Advocating for amendments to the Act of 3 October 2008 on the provision of information on the environment and its protection, public participation in environmental protection and environmental impact assessments. Position: Facilitating investments in pumped-storage power plants: recognising an investment accompanying a pumped-storage power plant investment as a strategic investment.
Submission of comments on the draft Act amending the Capacity Market Act (register number in the list of legislative and programme work of the Council of Ministers: UC70). Position: Ensuring the possibility of extending the validity of a certificate entitling participation in the secondary market and proposals to improve the organisation and conduct of supplementary auctions.
Submission of comments on the draft Act amending the Act on Renewable Energy Sources and certain other acts (UD41). Position: Removal of the regulation concerning the increase of the prosumer deposit value (correction factor 1.23) or ensuring compensation for sellers in this respect, and proposals aimed at accelerating the permitting process in the RES area.
Submission of comments on the draft Act amending the Act on investments in wind power plants and certain other acts (UD89). Position: Limiting the scope of information on wind power plants in the local spatial development plan (MPZP), clarifying provisions regulating the information provided to prosumers on energy settlement, facilitating the implementation of onshore wind farm investments, and extending the scope of application of cable pooling.
Advocating for amendments to the Act of 27 November 2024 amending the Act on the promotion of electricity generation in offshore wind farms, regarding the change of the delegation to issue a regulation defining the maximum price for electricity generation in offshore wind farms. Position: Introducing the possibility of determining different maximum prices separately for specific areas/groups of areas indicated in the annexes to the Act (taking into account parameters related to the implementation of investments in offshore wind farms, including the length of the connection in the offshore and onshore part, and the depth of the offshore wind farm foundation).
Advocating for amendments of the act of 27 November 2024 amending the Act on the promotion of electricity generation in offshore wind farms. Preparation of a draft of provisions aimed at effectively conducting auctions in 2025, as well as ensuring facilitation in the development and implementation of offshore wind farm projects and improving their scheduling and economic efficiency.
Name of the register for transparency or equivalent in which the undertaking is registered: EU Transparency Register, identification number: 818300434979-49.
GK PGE has no information on the appointment of members of administrative, management, or supervisory bodies who held comparable positions in public administration (including regulatory bodies) within two years preceding their appointment, during the current reporting period.